FAA – AOPA chatter about hours needed for Commercial to not include INST hours?

So, I have noticed a bunch of chatter from AOPA to the FAA about a LOI that the FAA put out regarding hours looged for the purposes of earning an instrument rating not counting towards the requirements of the Commercial license. This seems to fly in the face of all logic. It seems that the net conclusion from the chatter is that hours earned towards an instrument rating will / can count towards earning the Commercial license.

My question is ultimately, are you CFI's paying any attention to this, and now adding comments to the logbooks of your instrument students that the training given is meant to be applicable to 61.129 and 61.65, to make sure that this is "documented properly" as the AOPA response mentions?

By FAA regs, a commercial pilot (ie: flying in 135 charter ops) is pretty restricted, - no night, no distance > 50nm, etc. It seems on the one hand the FAA is saying, - get an instrument rating before becoming a Comm; but that training is not applicable? My recently minted IFR ticket gave me an understanding of the airspace system, and what goes on there beyond my expectations. If gave me a whole new appreciation for precise, deliberate, conscientious flying.

Ok - I'll admit it, I am cheap and I want my commercial license too, and don't want to pay for what I don't "have to". But can't the FAA see the mixed message here? Is this impacting how you are training students, and logging their training?

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2 Answers

I will be very interested to hear the experience of other CFIs. The only time I “designate” the type of instruction given is in my own logbook, and this only for reference.

When I log and endorse flight experience in a student’s logbook I always designate the specific type of training performed, whether this is “Syllabus lesson 14” or “Partial panel, VOR holding, 1 ILS Kxxx, 1 VOR Kxxx circle to land.” I don’t ever endorse as “instrument training” since this is inferred by the designation.

It’s clear that the FAA does not interpret the CFRs to describe flight experience as exclusive, as indicated by their obtuse comments (additionally see the add-on requirements for multi-engine). But I don’t understand what it means to “properly document” the training. Reading from the FAA letter:

“The reason for this is that the training required under 61.65(e) is general, while the training under 61.129(c)(3)(i) lists very specific operations that must be accomplished to satisfy the requirements.”

This seems to me to be a stupid sentence (are there new instrument procedures, other than those described as the instrument rating requirements) but I understand this to mean: “All apples are fruit but not all fruit are apples. The instrument rating requires a basket of fruit but the commercial certificate requires ten apples. One basket of fruit does not constitute ten apples, but if ten apples are contained in the one basket, these ten apples may be counted towards the ten apples required.”

Can you tell me how the Wings Flight Review works? I hear that you can skip the ground portion with an instructor if you complete it. I have been looking at doing it, but not sure what I all need to do. I see per the regulations that you can qualify for a Flight Review if you complete a phase of the FAA Wings course. Does this mean I just need to do the three ground credits myself and then go fly with an instructor? If so, what all does the instructor need to do?

Thanks,
Andy

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